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`YVES GHIAI-CHAMLOU,
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`Plaintiff,
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`vs.
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`RELIANT TITLE USA, LLC;
`HORIZON REALITY GROUP, LLC;
`BERKSHIRE
`HATHAWAY
`HOMESERVICES NEVADA; DOES
`I through XXX, inclusive, and ROE
`BUSINESS ENTITIES I through X,
`inclusive,
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`Defendants.
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`No. 83635
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`Electronically Filed
`Nov 12 2021 01:00 p.m.
`Elizabeth A. Brown
`MOTION FOR EXTENSION OF
`Clerk of Supreme Court
`TIME TO FILE DOCKETING
`STATEMENT
`CIVIL APPEALS
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`Appeal from Eight Judicial District
`Court Case No.: A-18-777196-C
`Hon: Susan H. Johnson
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`MOTION FOR EXTENSION OF TIME
`TO FILE DOCKETING STATEMENT
`(First Request)
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`Appellant hereby moves for a 30-day extension of time for filing the
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`Docketing Statement in this matter. The Docketing Statement is presently due for
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`filing on November 15, 2021. Therefore, appellant requests an extension until
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`December 15, 2021.
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`///
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`Docket 83635 Document 2021-32507
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`This Motion is brought pursuant to NRAP 26(b)(1)(A) on the grounds that
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`good cause exists to enlarge the time to file the Docketing Statement and is based on
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`this motion, the attached Memorandum of Points and Authorities and Declaration of
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`Leo P. Flangas, Esq., the papers and pleadings on file and on such other oral or
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`documentary evidence that may be subsequently presented.
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`DATED: November 11, 2021.
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`/s/ Leo P. Flangas
`LEO P. FLANGAS, Esq.
`Nevada Bar No.: 5637
`Telephone: (702) 384-1990
`Fax: (702) 384-1009
`600 S. Third Street
`Las Vegas, NV 89101
`Attorney for Appellant
`MEMORANDUM OF POINTS AND AUTHORITIES
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`I.
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`GOOD CAUSE EXISTS TO ENLARGE TIME
`TO FILE THE DOCKETING STATEMENT
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`NRAP 26(b)(1)(A) provides in relevant part:
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`For good cause, the court may extend the time prescribed by
`these Rules or by its order to perform any act, or may permit an
`act to be done after that time expires……….
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`Mr. Flangas respectfully requests the Court to grant an extension of time to
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`file the Docketing Statement. Mr. Flangas has had a heavy trial schedule and did
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`not have assistance in preparing the Docketing Statement. Therefore, these other
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`matters took precedence and hindered our ability to timely file the docketing
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`statement. Although the undersigned has been working to draft the Docketing
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`Statement, Appellant’s attorney will be unable to complete it by the current deadline.
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`CONCLUSION
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`Accordingly, due to the foregoing, Appellant respectfully submits that good cause
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`exists for this Court to grant an additional 30 days to file the Docketing Statement.
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`If granted, the new due date would be December 15, 2021. This request is being
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`made in good faith, without the intent to delay this appeal unnecessarily.
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`Dated this 12TH day of November 2021.
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`/s/ Leo P. Flangas
`LEO P. FLANGAS, Esq.
`Nevada Bar No.: 5637
`Telephone: (702) 384-1990
`Fax: (702) 384-1009
`600 S. Third Street
`Las Vegas, NV 89101
`Attorney for Appellant
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`DECLARATION OF LEO P. FLANGAS
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`I, LEO P. FLANGAS, declare as follows:
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`1.
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` I am attorney licensed to practice before all the courts of the State of Nevada.
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`All of the fact set forth here are true of my own personal knowledge. If called to
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`testify I could, and would, testify as to them.
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`2.
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`3.
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`I represent the Appellants in the above referenced case.
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`I have had a heavy trial schedule and did not have assistance to date in
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`preparing the docketing statement.
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`4.
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`This is my First Request for an extension of time to file the Docketing
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`Statement.
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`I declare under penalty of perjury under the laws of the State of Nevada that
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`the foregoing is true and correct.
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`Executed this 12th Day of November 2021 at Las Vegas, Nevada.
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`/s/ Leo P. Flangas
`LEO P. FLANGAS, Esq.
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`CERTIFICATE OF SERVICE
` certify that on this date I electronically filed the foregoing document with
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` I
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`the Clerk of the Nevada Supreme Court, and therefore electronic service was made
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`in accordance with the master service list and includes, but is not limited to the
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`following:
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`Jay Kenyon, Esq.
`702-888-0000
`YAN KENYON
`7881 W. Charleston Blvd. Suite 165
`Las Vegas, NV 89117
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`J. Daniel Weidner, ESQ. (pro hoc vice)
`402-390-9500
`KOLEY JESSEN, P.C., L.L.O.
`1125 South 103rd St., Suite 800
`Omaha, NE 68124
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`Attorneys for Reliant Title USA, LLC
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`DATED: November 12, 2021
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`/s/Natasha Smith
`For the firm
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